Protest challenging the evaluation of the protester’s management approach is denied. The agency found the protester’s management approach did not describe how the protester would measure performance. The protester alleged the agency applied unstated criteria because the solicitation did not require offerors to describe how they would measure performance. GAO noted that while the solicitation did not explicitly require vendors to address how the would measure performance, the evaluation criteria permitted the agency to consider how performance would be measured. The protester also argued this quotation showed how it would measure performance. But GAO found that the protester’s quotation lacked sufficient detail.
The General Services Administration issued an RFQ on behalf of the Department of Housing and Urban Development seeking information technology services. The RFQ contemplated the establishment of blanket purchase agreements. The agency would issue task order under the agreements on a best value basis.
In issuing task orders, the agency would evaluate non-price factors, including vendors’ management approach. The RFQ provided that a vendor’s management approach had to describe their methodology for meeting performance measure, and that vendors should not just submit generic quality control processes. GSA would evaluate each approach to assess the degree to which the quotation reflected an effective plan and an understanding of the operating environment.
Lamb Informatics, Ltd. submitted in a quotation. GSA assessed a deficiency to its management approach, finding that it lacked detail. Specifically, GSA noted, Lamb had set forth what it wanted to do but had not explained how it would do it. As a result of this deficiency, Lamb’s quotation was unacceptable. Following award, Lamb protested.
Lamb argued that the agency applied unstated criteria in evaluating it management approach. Lamb contended that while GSA had assessed a deficiency for failing to describe how it would measure performance, nothing in the RFQ required vendors to demonstrate how they would measure performance.
GAO rejected this argument. While the RFQ did not explicitly require that vendors demonstrate how they would measure performance, the RFQ nonetheless instructed vendors to describe their methodology and approach, and that the agency would evaluate whether the approach reflected an effective and efficient plan. This language permitted consideration of how performance would be measured.
As an alternative argument, Lamb alleged that even if the RFQ required vendors to explain how they would measure performance, Lamb’s quotation had effectively shown this. Lamb contended that a portion of its proposal contained a comprehensive list of performance measures it would employ.
But GAO determined that the GSA had reasonably found that Lamb’s performance measures contained little description of explanation of the concrete steps the company would take to measure performance. Again, GAO noted that Lamn’s quotation stated what the company proposed to do but did not describe how it accomplish the proposed result. The agency had found that Lamb’s managers approach was “generic and aspirational. GAO saw no basis to question this assessment.
Lamb is represented by Lawrence P. Block and Elizabeth G. Leavy of Reed Smith LLP. The intervenor, Pyramid Systems, Inc., is represented by J. Scott Hommer, Rebecca A. Pearson, Krista A. Nunez, Taylor A. Hillman, and Caleb E. McCallum of Venable, LLP. The agency is represented by Jackson Reams of the General Services Administration. GAO attorneys Christopher Alwood and Christina Sklarew participated in the preparation of the decision
